Speak up for orcas: strengthen rules around whale watching!

Washington Department of Fish and Wildlife (WDFW) is in the process of developing commercial whale watching license rules to reduce the daily and cumulative impacts to orcas and ensure sustainable whale watching. A Draft Environmental Impact Statement (DEIS) has been developed to help inform and support this process. We have concerns about the validity of this DEIS as a foundation for good decision-making, both now as the draft rules are being crafted and finalized, and in the future when adaptive management is applied as the population either recovers or declines further.

Please submit your comments on the DEIS today.

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Subject:

DEIS Commercial Whale Watching Licensing Program

Dear Washington Department of Fish and Wildlife (WDFW),

Thank you for the opportunity to provide comments on the draft environmental impact statement (DEIS) for the Commercial Whale Watching Licensing Program.

The DEIS does little to support the intent of the legislation that directs Washington Department of Fish and Wildlife to develop a commercial whale-watching license program that “must effectively reduce the daily and cumulative impacts on southern resident orcas and consider the economic viability of license holders.” The rules must be based on the best available science and apply the precautionary principle, given the crisis facing this highly endangered species and the opportunity to quickly address the threat of noise and disturbance while continuing to work on other threats.

The DEIS has numerous shortcomings and fails to incorporate the best available science in analyzing the environmental impacts of vessel noise and disturbance from commercial whale watch vessels on the Southern resident orca population. The precautionary principle should be a guide to the DEIS but it is not. Given the precarious status of this fragile population, every interaction from commercial whale watch operators with Southern Resident orcas should be treated as an opportunity for disturbance.

In short;

1. The alternatives laid out in this DEIS are not sufficiently clear, specific, or concrete to support good decision-making or allow for adequately informed public comments.

2. The “most restrictive” alternative is flawed. There should be an alternative that clearly states 0 motorized commercial whale-watching boats in the vicinity of southern resident orcas (at least 0.5 nautical miles) for the full year. That would be most precautionary and protective.

3. Alternative 3 is not meaningfully different from Alternative 4 (status quo). Alternative 3 should be more different from the status quo alternative.

4. The methodology used for calculating the percent reduction in viewing days is flawed.  The results of this calculation are meaningless, since the methodology does not consider which months would carry restrictions, nor does it consider overlaps with either the typical southern resident presence in the inland waters or the peak whale-watching season. If the restricted months were the winter months, when the southern residents are less likely to be in the inland waters and the commercial whale-watching operators are unlikely to be offering tours, the actual number of viewing days would be unlikely to decrease at all, in practice. The alternatives must be more specific of the relative impacts of restrictions in different seasons, given seasonal trends in southern resident orca presence and commercial whale-watching activity.

5. The DEIS lacks basic biological information about the southern resident orca population and full discussion of the best available science around vessel noise and disturbance on orcas. Factors affecting whales include the number of vessels, speed, distance and type of vessels. The Washington State Academy Science panel documents and reports numerous studies on the direct impacts and short-term behavioral changes affecting orcas from the presence and noise of vessels. It is necessary to present this information in the DEIS in order to evaluate and analyze the direct and direct effects from each alternative.

6. It is out of the scope of the DEIS and not part of the legislative mandate to be considering the recreation opportunities provided by commercial whale-watching operations and impacts to “recreators”. This should be removed in the Final EIS.

7. Reporting requirements should include reporting to the Whale Report Alert System (WRAS) component in each alternative and AIS should be included in Alternatives 1 and 2 and 3, not left to the “mitigation measure” category.

I hope these issues will be fully addressed in the Final EIS.

Regards, Your Name

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